PRIVACY POLICY

ARC Luminous Management Company LLC Privacy Policy
Last Updated: October 16, 2023

This Privacy Policy applies to our website located at Luminous (luminouscapitalinc.com) (the
“Site”). It describes how ARC Luminous Management Company LLC, (“Luminous Capital,”
“we,” “us,” or “our”) may collect, use, share and disclose Personal Information we collect
on the Site, as well as your rights, where applicable, in respect of such Personal
Information. Any capitalized words not defined in this Privacy Policy shall have the
meaning assigned to them in the Terms of Use.
This Privacy Policy does not apply to your use of Luminous Capital’s financial services,
including any investments. Please refer to the separate privacy policy or policies provided
to you for further information about our collection and use of Personal Information for
such services. The Site may in the future also link to other third-party websites, products or
services not owned or controlled by Luminous Capital (“External Sites”). This Privacy
Policy does not apply to those any of such External Sites, and Luminous Capital is not
responsible or liable for the data collection practices of any such third parties, including the
practices of the third-party that administers your investor account.
If you have any questions about our privacy practices or whether this Privacy Policy
applies to you, please contact us as described at the end of this document.

I. The Information We Collect and Use
When we use the term “Personal Information,” we mean information that can be used to
identify you directly or indirectly as an individual person or your household, such as your
name or contact details. We may collect and use the following categories of Personal
Information through your use of our Site:
• Internet or Other Electronic Network Activity Information, such as your
internet protocol (IP) address, login data, unique device identifiers, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform, mobile device carrier and other technology on the
devices you use to access our Site; as well as usage information, such as information
about how you use our Site and our products and services, referring/exit web pages,
date/time stamps, error logs, and the frequency of your use of our Site;

• Any other Personal Information you choose to voluntarily provide to us
(“Additional Information”), such as your contact information if you reach out to us
with questions or requests.
We may collect and use this Personal Information so we can respond to your requests,
comply with our legal obligations, and carry out and improve our business.
We also collect, use and share aggregated information such as statistical or demographic
data for any purpose. This information could be derived from your Personal Information
but will not directly or indirectly reveal your identity. For example, we may aggregate your
usage information to calculate the percentage of users accessing a specific Site feature.
However, if we combine or connect information with your Personal Information so that it
can directly or indirectly identify you, we treat the combined information as Personal
Information which will be used in accordance with this Privacy Policy.

II. How We Collect Your Information
We collect Personal Information in a number of ways:
1. Personal Information You Provide to Us
We collect Personal Information when you choose to share that information with us. For
example, if you contact us through email, we collect whatever information you supply and
use this information to communicate with you if requested, and otherwise fulfill the
purpose of the submission.
Where you provide Personal Information on behalf of other individuals, you are
responsible for notifying those individuals that you have provided their Personal
Information to us and directing them to this Privacy Policy so they understand how we will
process their Personal Information.

2. Information Collected Automatically
We may use various technologies to collect other types of data that generally do not
directly reveal your identity (“Other Information”), including with your consent where
required by applicable law. If we associate Other Information with Personal Information, or
if Other Information otherwise constitutes Personal Information under applicable data
protection law(s), we will treat the combined information as Personal Information in
accordance with this Privacy Policy.
• Logging Functionality: We may gather certain information automatically and store
it in log files. This information may include IP addresses, browser type, internet

service provider, referring/exit pages, operating system, date/time stamp and/or
clickstream data. We generally only use this data for purposes such as security,
fraud detection, and protecting our rights.
• Cookies: We only use so-called “essential” or “strictly necessary” cookies, which are
essential for the Site to function correctly, and which expire at the end of each
session.

III. For What Business Purpose We Use Your Information
We will only use or otherwise process your Personal Information when and how the law
allows us to. In addition to the uses described above, we may process Identifiers and
Contact Information, Internet or Other Electronic Network Activity Information, Marketing
and Communications Information, Additional Information, and Other Information for the
following business purposes:
• Contractual Obligations: We need to process certain Personal Information in order
to provide you with the services you requested, and without it we would not be able
to provide you with some or all portions of the services that require such data.
• Information Security: We process Identifiers and Contact Information and Internet
or Other Electronic Network Activity Information when you use the Site in order to
maintain an audit log of activities performed. We use this information pursuant to
our legitimate interests in tracking usage, combating cybersecurity attacks, and
removing or defending against malicious individuals or programs.
• Operation and Improvement of our Services: We process Internet or Other
Electronic Network Activity Information pursuant to our legitimate interest in
operating and improving our services.
• General Business Development and Management: We process Identifiers and
Contact Information, Marketing and Communications Information, and Additional
Information pursuant to our legitimate interest in creating and managing our
business relationships with existing and prospective clients and other individuals
interested in our business, including without limitation:
o To respond to inquiries;
o To provide information about our products and services; and
o To assist our clients with any issues while using the services.
• Protection of Rights: We may disclose any categories of Personal Information to
respond to claims of violation of third-party rights or to enforce and protect our
rights.
• Legal Obligations: We may be required to disclose Personal Information in
response to lawful requests by public authorities, including for the purpose of
meeting national security or law enforcement requirements. We may also disclose

Personal Information to other third parties when compelled to do so by government
authorities or required by law or regulation including, but not limited to, in
response to court orders and subpoenas.
In some cases, we process Personal Information based on the consent you expressly grant
to us at the time we collect such data. When we process Personal Information based on
your consent, it will be expressly indicated to you at the point and time of collection. You
can withdraw your consent at any time. You can do this by contacting us as described at the
end of this Privacy Policy. Should we wish to use Personal Information for other specific
purposes (including, if applicable, any purpose that requires your consent), we will contact
you. We will not use Personal Information for any purposes inconsistent with this Policy
(and the other privacy notices or policies provided to you or otherwise made available by
us from time to time) without your permission.

IV. When We May Share Your Information with Others
We do not sell Personal Information obtained about you to any third parties and have not
done so in the twelve (12) months preceding the effective date of this Privacy Policy, nor do
we share Personal Information obtained about you with third parties for the purpose of
cross-context behavioral advertising.
We do not disclose your Personal Information to anyone other than as described in this
Privacy Policy (and the other privacy notices or policies provided to you or otherwise made
available by us from time to time), as required by applicable law or regulation, or unless we
have your consent to do so. This means we may share your Personal Information in the
following ways:
• Service Providers: We share your Personal Information with third-party service
providers (including financial, technical, and professional service providers and
consultants) who perform services on our behalf or for your benefit, such as web
hosting, or financial institutions that provide services to Luminous Capital.
• Affiliates: We may share your information with affiliated legal entities within our
family of companies for purposes and uses that are consistent with this Privacy
Policy.
• Legal Process, Safety and Terms Enforcement: We may disclose your Personal
Information to legal or government regulatory authorities in response to their
requests for such information or to assist in investigations. We may also disclose
your Personal Information to third parties in connection with claims, disputes or
litigation, when otherwise required by law, or if we determine its disclosure is
necessary to protect the health and safety of you or us, or to enforce our legal rights
or contractual commitments that you have made.

• Business Transfers: Your Personal Information may be disclosed as part of a
corporate business transaction, such as a merger, acquisition, joint venture, or
financing or sale of company assets, including bankruptcy proceedings, and could be
transferred to a third-party as one of the business assets in such a transaction. It
may also be disclosed in the event of insolvency, bankruptcy or receivership.

V. How We Protect Your Information
We are committed to maintaining the confidentiality, integrity and security of your
Personal Information and take precautions to protect such information. These precautions
include the adoption of certain physical, electronic, and procedural safeguards and
procedures designed to maintain and secure your Personal Information from inappropriate
disclosure in accordance with applicable laws and regulations.
Unfortunately, the transmission of information via the Internet is not completely secure
and, although we will take steps to protect your Personal Information, we cannot guarantee
the security of your Personal Information transmitted via the Site; any transmission is
therefore at your own risk.

VI. How We Transfer Your Information
The Personal Information that we collect or that you submit may be transferred to,
processed in, and held by Luminous Capital or its third-party service providers in countries
(including the United States) other than the one in which you reside. Such transfers are a
necessary part of the services that we provide. By submitting your Personal Information to
us, you acknowledge this may involve the transfer, storing or processing of your Personal
Information in countries (including the United States) other than the one in which you
reside.

VII. How Long We Retain Your Information
We will retain your Personal Information only for as long as is necessary for the purposes
set out in this Privacy Policy, or as long as we are legally required or permitted to do so.
Under certain circumstances, you may have the right to have your Personal Information
erased.
When deciding how long to retain your Personal Information, we take into account our
legal and regulatory obligations, the amount, nature, and sensitivity of the Personal
Information, the potential risk of harm from unauthorized use or disclosure of your
Personal Information, the purposes for which we process your Personal Information

described above and whether we can achieve those purposes through other means. We
may also retain your Personal Information to investigate or defend against potential legal
claims in accordance with the limitation periods of countries where legal action may be
brought.

VIII. Children’s Privacy
The Site is not directed toward children under the age of 18. We do not promote our
products or services online to minors, and we do not intentionally collect any Personal
Information from any person under 18. If we become aware of having collected Personal
Information from children under the age of 18 without valid consent from their respective
parents or guardians, we will delete it as soon as practical.

IX. How You Can Manage Your Information
· Updating Your Information: We will make reasonable efforts to ensure that all
Personal Information that we hold about you is accurate, complete and up to date. You can
help in this regard by promptly notifying us if there are any significant changes to your
Personal Information (such as a change of name, address or contact details).
· Deleting Your Information: We will comply with deletion requests within a
reasonable time to the extent permissible or required by law. However, we will not delete
data that we are legally required to maintain (such as information regulators require for
audit or substantiation purposes), or data still needed for a business purpose (such as data
on archived back-up tapes).

X. Notice to California Residents

1. Your Privacy Rights
Pursuant to the California Privacy Rights Act (“CPRA”), residents and households located in
the state of California have the following rights regarding the processing of their Personal
Information:

a) Right to Know About Your Personal Information

You have the right to request that we disclose information to you about our collection,
disclosure, sale and use of your Personal Information. If you would like to know the specific
pieces of Personal Information we have collected about you, please contact us as described
below under “How to Contact Us,” and we will provide you with the information collected
on or after January 1, 2022. You may exercise this right up to two times in any 12-month
period.

b) Right to Request Deletion
You have the right to request deletion of your Personal Information. We will honor such
request if we can, but might not be able to fulfill your request if we (or our service
providers) are required to retain your Personal Information.

c) Right to Request Correction
You have the right to request that we correct inaccurate Personal Information that we
maintain about you.

d) Right to Opt-Out of the Sale or Sharing of Personal Information
You have the right to opt-out of the sale or sharing of Personal Information. Please note,
however, that we do not sell or share for the purpose of cross-context behavioral
advertising any Personal Information obtained about you, nor have we done so in the past.

e) Right to Limit the Use and Disclosure of Sensitive Personal Information
You have the right to limit the use and disclosure of sensitive Personal Information. Please
note, however, that we only collect the information mentioned in this CPRA Notice, and do
not use or disclose it for any purposes that are covered by this right (nor have we done so
in the past).

f) Right to Non-Discrimination
We will not discriminate against you for exercising any of your CPRA rights. We will not (i)
deny you products or services, (ii) charge you different prices or rates for products or
services, including through granting discounts or other benefits, or imposing penalties

(except for financial incentives permitted by the CPRA, see below), (iii) provide you a
different level or quality of products or services, and (iv) suggest that you may receive a
different price or rate for products or services or a different level or quality of products or
services.

g) Right to Designate an Authorized Agent
If you submit a request to know or delete your Personal Information through the use of an
authorized agent, we may require that you (i) provide the authorized agent written
permission to act on your behalf, and (ii) verify their identity directly with us.

2. Exercising Your Privacy Rights
To exercise the rights described above, please submit a request to us by using the methods
outlined under “How to Contact Us” below with the subject line “CPRA Request”.

a) What We Need to Know to Fulfill Your Request
The request must: (i) provide sufficient information that allows us to reasonably verify you
are the person about whom we collected Personal Information or an authorized
representative; and (ii) describe your request with sufficient detail that allows us to
properly understand, evaluate, and respond to it. We cannot respond to your request or
provide you with Personal Information if we cannot verify your identity or authority to
make the request and confirm the Personal Information related to you. Making a request
does not require you to create an account with us.

b) How You Will Hear Back from Us
We will confirm receipt of a request within ten (10) business days of its receipt and
endeavor to respond within forty-five (45) calendar days of its receipt. If we require more
time, we will notify you of the extension and provide an explanation of the reason for the
extension in writing, and we will provide you with a response no later than ninety (90)
calendar days of receipt of the request. The response we provide will also explain the
reasons we cannot comply with a request, if applicable.
We may charge a reasonable fee to process or respond to your requests if they are
excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a

fee, we will inform you of the reasons for this decision and provide you with a cost estimate
before completing your request.

3. Other California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the
right to obtain certain information about the types of Personal Information that companies
with whom they have an established business relationship (and that are not otherwise
exempt) have shared with third parties for direct marketing purposes during the preceding
calendar year, including the names and addresses of those third parties, and examples of
the types of services or products marketed by those third parties. In order to submit such a
request, please contact us as described below. Please note, however, that we do not
disclose Personal Information to third parties for such third parties’ direct marketing
purposes.

XI. Notice to Nevada Residents
If you are a Nevada resident, you have the right to submit a request directing us not to sell
your Personal Information. In order to submit such a request, please contact us as
described below. Please note, however, that we do not sell consumers’ covered information
for monetary consideration (as defined in Chapter 603A of the Nevada Revised Statutes).

XII. Changes to this Privacy Policy
This Privacy Policy is subject to occasional revision, without prior notice, so please review
it frequently. If we make any material changes in the way we use your Personal
Information, we will notify you by updating the effective date above, or as otherwise
required by law.

XIII. How to Contact Us
If you have any questions or comments about this Privacy Policy or other privacy-related
matters, you may contact us via our email at Info@luminouscap.ca.